16ph Privacy Policy

1. Introduction

16ph ("we", "us", "our") is committed to protecting the privacy and personal data of all users of the 16ph online gaming platform ("the Platform"). This Privacy Policy describes how 16ph collects, uses, stores, shares, and protects personal information provided by or collected from users ("you", "your") in connection with your use of the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission ("NPC"). 16ph takes its obligations as a personal information controller seriously and has implemented appropriate technical and organizational measures to safeguard your data.

This Privacy Policy should be read together with the 16ph Terms & Conditions, which govern your use of the Platform. By using the Platform, you confirm your agreement to both documents.

2. Personal Data We Collect

16ph collects the following categories of personal data from users of the Platform:

2.1 Identity & Contact Information

• Full legal name as it appears on your government-issued Philippine identification document
• Date of birth (used to verify the 21+ age requirement)
• Philippine mobile number
• Email address
• Residential address (province, city/municipality)
• Government-issued ID type and number (for KYC verification)

2.2 Financial Information

• GCash or PayMaya mobile wallet number
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where provided for withdrawal purposes
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Payment method ownership verification documents

2.3 Gaming Activity Data

• Game history, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Session duration and frequency of play
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

2.4 Technical & Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser type
• Cookies and similar tracking technologies (see Section 8)
• Login timestamps and session data
• Platform interaction data (pages visited, features used)

2.5 Communications Data

• Records of communications between you and 16ph customer support
• Feedback, complaints, and dispute records
• Marketing communication preferences

16ph collects only the minimum personal data necessary for the purposes described in this Privacy Policy. We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable law or regulation.

3. How We Collect Your Data

16ph collects personal data through the following means:

3.1 Directly From You

The majority of personal data we hold is provided directly by you when you register an account on the Platform, complete identity verification (KYC), make a deposit or withdrawal, contact customer support, or participate in promotions and surveys.

3.2 Automatically Through the Platform

When you access and use the 16ph Platform, certain technical and usage data is collected automatically through cookies, log files, and similar technologies. This includes your IP address, device information, and browsing behavior on the Platform. See Section 8 for more details on our use of cookies.

3.3 From Third Parties

In certain circumstances, 16ph may receive personal data about you from third parties, including:

• Payment service providers (e.g., GCash, PayMaya, BPI, BDO, Metrobank) for the purpose of verifying transactions
• Identity verification service providers used to assist with KYC compliance
• Fraud prevention and anti-money laundering screening services
• Regulatory authorities, where required by law

4. How We Use Your Personal Data

16ph uses the personal data we collect for the following purposes:

16ph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable Philippine law.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 16ph processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and 16ph (i.e., to provide the gaming services you have registered for, process your transactions, and manage your account).
• Legal obligation: Processing is necessary for 16ph to comply with applicable Philippine laws and regulations, including KYC requirements, AML obligations, and regulatory reporting requirements.
• Legitimate interests: Processing is necessary for the legitimate interests of 16ph, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: Where 16ph relies on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time by contacting us at [email protected].

6. Data Sharing & Disclosure

16ph does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

6.1 Service Providers

16ph engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank, InstaPay), identity verification providers, cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on 16ph's instructions and in accordance with applicable data privacy law.

6.2 Regulatory & Law Enforcement Authorities

16ph may disclose your personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required to do so by law, court order, or regulatory directive. This includes disclosures required under Philippine AML laws and gaming regulations.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 16ph's assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

6.4 With Your Consent

16ph may share your personal data with other third parties where you have given your explicit consent to such sharing.

7. Data Retention

16ph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule, 16ph retains account and transaction data for a minimum of five (5) years following the closure of your account, in accordance with Philippine AML regulations and gaming regulatory requirements. Gaming activity data and communications records are retained for a minimum of three (3) years.

Where personal data is no longer required for any lawful purpose, 16ph will securely delete or anonymize it in accordance with our internal data retention and disposal procedures. Anonymized or aggregated data that can no longer identify you may be retained indefinitely for analytical and platform improvement purposes.

If you request the closure of your 16ph account, we will retain your personal data for the minimum period required by applicable Philippine law before securely disposing of it.

8. Cookies & Tracking Technologies

16ph uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. The following types of cookies are used by 16ph:

8.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting the functionality of the Platform.

8.2 Performance & Analytics Cookies

These cookies collect anonymized information about how users interact with the Platform, such as which pages are visited most frequently and whether users encounter error messages. This data helps 16ph improve the performance and usability of the Platform.

8.3 Functional Cookies

These cookies allow the Platform to remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations, to provide a more personalized experience.

8.4 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform and your ability to access certain features. For more information on managing cookies, refer to your browser's help documentation.

9. Data Security

16ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 16ph Platform
• Encryption of sensitive data at rest, including account credentials and financial information
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security assessments and vulnerability testing of the Platform
• Two-factor authentication options for player accounts
• Continuous monitoring for suspicious activity and unauthorized access attempts
• Staff training on data privacy and security obligations

While 16ph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 16ph will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

You are responsible for maintaining the confidentiality of your 16ph account credentials. If you suspect that your account has been compromised, please contact us immediately at [email protected].

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by 16ph:

• Right to be Informed: You have the right to be informed about how your personal data is being collected and processed, which is the primary purpose of this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data that 16ph holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data that 16ph holds about you.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 16ph's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that 16ph has not handled your personal data in accordance with applicable law.

To exercise any of the above rights, please submit a written request to [email protected]. 16ph will respond to all data rights requests within fifteen (15) business days of receipt. We may require you to verify your identity before processing your request.

11. Children's Privacy

21+ The 16ph Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. 16ph does not knowingly collect personal data from individuals under the age of 21.

If 16ph becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on the Platform, please notify us immediately at [email protected].

16ph employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time. Accounts found to belong to individuals under 21 years of age will be permanently closed and any associated funds will be handled in accordance with applicable Philippine law.

12. International Data Transfers

16ph primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, for example where cloud infrastructure or technical support services are provided by international vendors.

Where personal data is transferred outside the Philippines, 16ph ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual data processing agreements incorporating standard data protection clauses approved by the National Privacy Commission.

By using the 16ph Platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Privacy Policy, subject to the safeguards described above.

13. Third-Party Links

The 16ph Platform may contain links to third-party websites or services for informational purposes. This Privacy Policy applies solely to the 16ph Platform and does not cover the privacy practices of any third-party websites or services. 16ph is not responsible for the content or privacy practices of any third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

14. Updates to This Privacy Policy

16ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. The date of the most recent revision will always be displayed at the top of this page.

Where changes to this Privacy Policy are material, 16ph will notify registered users via the email address or mobile number associated with their account, or by displaying a prominent notice on the Platform, prior to the changes taking effect. Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 16ph protects your personal data.

15. Contact & Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 16ph, please contact our Data Privacy Officer:

• Email: [email protected]
• Subject Line: Data Privacy Request – [Your Full Name]
• Response Time: Within 72 hours for all privacy-related inquiries
• Support Hours: 24 hours a day, 7 days a week

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your privacy concern.